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ARTICLE · 16 JANUARY 2025

Form PF Compliance Amid Recent SEC Enforcement Actions And Upcoming Deadlines

Crowell & Moring LLP
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Form PF and the General Instructions have undergone significant revisions in recent years. The most recent changes, finalized February 8, 2024, with a fast-approaching March 12, 2025...

United StatesFinance and Banking
Christopher Mendez
Christopher Mendez
Daniel L. Zelenko
Daniel L. Zelenko

Form PF and the General Instructions have undergone significant revisions in recent years. The most recent changes, finalized February 8, 2024, with a fast-approaching March 12, 2025 compliance date, introduced prescriptive filing requirements regarding the aggregation of private funds and other entities, with significant changes to the General Instructions and Form PF questions.1 The February 8, 2024 amendments follow the SEC's May 3, 2023 amendments, which marked the first major update to Form PF since its inception and significantly expanded private fund reporting obligations. The SEC's recent enforcement actions and significant amendments to Form PF have heightened regulatory expectations for private fund advisers. With the March 12, 2025 compliance date fast approaching, private fund advisers must prioritize compliance and operational readiness to ensure timely and accurate reporting of Form PF.

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